Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Imported molybdenum mirrors and shields, cut and curved for use in automobile lamps, ceased to retain the character of sheets and became distinct articles of molybdenum. Applying the General Rules for Interpretation and the principle that a product transformed into a new commercial and functional article cannot be classified as the original raw sheet, the Tribunal held that the goods were not classifiable under the tariff entry for bars, rods, profiles, plates, sheets, strips and foil. As the competing residual entry was the more appropriate classification, the goods were held classifiable under CTH 81029900 as other articles of molybdenum, and the departmental appeals were allowed.
Imported molybdenum mirrors and shields, cut and curved for use in automobile lamps, ceased to retain the character of sheets and became distinct articles of molybdenum. Applying the General Rules for Interpretation and the principle that a product transformed into a new commercial and functional article cannot be classified as the original raw sheet, the Tribunal held that the goods were not classifiable under the tariff entry for bars, rods, profiles, plates, sheets, strips and foil. As the competing residual entry was the more appropriate classification, the goods were held classifiable under CTH 81029900 as other articles of molybdenum, and the departmental appeals were allowed.
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